This Guidance Notice focuses on investor loans obtained from a third party for the purposes of investment (“off-book lending”) and holds that dealers must have adequate systems and controls to flag any investor accounts that involve off -book lending whether recommended by the investment adviser or not. The Guidance does recognize that where off-book loans are instigated by the client, they may be difficult to detect or supervise and therefore is “not expecting” “an expansive compliance framework to identify and monitor such loans”. It provides that off book lending be subject to preapproval. It also recommends best practices for both registered representatives and their dealers. Highlights are summarized here.